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What Is ReFuelEU Aviation? The EU SAF Mandate Explained

13 min read · May 18, 2026 · By Alex

ReFuelEU Aviation is the EU regulation that obliges fuel suppliers to put a rising share of sustainable aviation fuel (SAF) into the jet fuel they supply at EU airports. For a SAF developer in Southeast Asia, it is the clearest piece of regulated demand on the table. Yet it is also easy to misread. Therefore this guide walks through the text article by article, then sets out what it does and does not do for your revenue, your contract and your lender.

In short

ReFuelEU Aviation is Regulation (EU) 2023/2405. In fact it applies from 1 January 2024, and its core obligations apply from 1 January 2025.
Fuel suppliers must make a minimum share of SAF available at EU airports: 2 % in 2025, rising to 70 % in 2050.
Within that share, synthetic aviation fuels carry their own sub-target: 1.2 % on average in 2030 and 2031, 5 % in 2035, 35 % in 2050.
Meanwhile airlines have their own obligation. Thus they must uplift at least 90 % of the fuel they need at a given EU airport, which is the anti-tankering rule.
In fact the rule creates regulated demand. However it does not set a price and it does not sign a contract for you.
For a Southeast Asia plant, the open question is who buys, under what contract, and with which certification.

What ReFuelEU Aviation is, and who it binds

The regulation was signed on 18 October 2023 and published in the Official Journal of the EU on 31 October 2023. It applies from 1 January 2024, except Articles 4, 5, 6, 8 and 10, which apply from 1 January 2025. Moreover it belongs to the “Fit for 55” package. That package is the EU’s set of measures to cut net greenhouse gas emissions by at least 55 % by 2030, compared with 1990.

In practice the regulation binds three groups. For example aviation fuel suppliers must make a minimum share of SAF available to aircraft operators at EU airports. Aircraft operators must respect the fuel uplift rule and report every year. Airports in scope must give operators access to fuel that contains the minimum SAF share.

In addition the scope reaches two thresholds. For example it covers airports with more than 800 000 passengers or 100 000 tonnes of freight in the previous reporting period. Moreover it covers operators with at least 500 commercial passenger flights, or 52 all-cargo flights, departing from EU airports. By contrast small aerodromes and small operators stay outside the rule. In fact, according to the European Commission, more than 95 % of air transport departing from EU airports is covered anyway, so the thresholds trim the tail of the market rather than its core.

The ReFuelEU Aviation SAF blending schedule

In addition the minimum share of SAF grows in steps, and Annex I of the regulation sets the values out year by year. In other words the regulation hands a developer a demand curve out to 2050.

Year	Minimum SAF share
2025	2 %
2030	6 %
2035	20 %
2040	34 %
2045	42 %
2050	70 %

Above all these are minimums at the pump, not purchase obligations aimed at any single plant. Therefore a supplier that misses the share faces a fine calculated on the price gap, not on a fixed tariff. For a developer, that is the first place where the rule touches money.

The synthetic fuel sub-mandate under ReFuelEU Aviation

Moreover the regulation does not treat all SAF alike. Synthetic aviation fuels, meaning fuels made from renewable hydrogen and captured carbon, carry their own floor inside the overall share. In addition, according to Annex I, that floor rises in two stages before 2035.

Period	Synthetic share	Detail
2030 to 2031	1.2 % on average	At least 0.7 % in each of the two years
2032 to 2034	2.0 % on average	At least 1.2 % in 2032 and 2033, at least 2.0 % in 2034
2035	5 %	Yearly minimum
2040	10 %	Yearly minimum
2045	15 %	Yearly minimum
2050	35 %	Yearly minimum

Consequently the early sub-target is small in volume but demanding in engineering. For example a 2030 floor of 0.7 % a year on the EU jet fuel pool is a quantity that only a handful of plants can serve. Indeed the reason is that e-SAF needs renewable hydrogen, a carbon source and a certified pathway. In practice that scarcity is where an Asian e-SAF developer holds the most pricing power. It is also where the certification burden weighs heaviest.

What counts as SAF under ReFuelEU Aviation

In practice only drop-in fuels count, meaning fuels that can replace conventional jet fuel without changes to the airframe or the engine. Article 3(7) of the regulation defines SAF as one of three things. It is either synthetic aviation fuel, aviation biofuel, or recycled carbon aviation fuel.

Aviation biofuels, in turn, cover advanced biofuels made from feedstocks in Part A of Annex IX to the Renewable Energy Directive. Those feedstocks include agricultural and forestry residues, algae and bio-waste. Also they cover biofuels from Part B feedstocks such as used cooking oil and certain animal fats. Finally they cover other biofuels that meet the sustainability and greenhouse gas criteria of Articles 29 and 30 of that directive. However the final text excludes biofuels made from food and feed crops.

Therefore the first question a lender asks is simple. Which list does your feedstock sit on, and can you prove it? Under Commission Delegated Regulation (EU) 2023/1185, recycled carbon fuels and renewable fuels of non-biological origin must deliver at least 70 % greenhouse gas savings against the fossil comparator. Thus certifying that figure batch by batch is the work that precedes any contract.

In addition the regulation lets a supplier meet the share with renewable hydrogen for aviation or with low-carbon aviation fuels. That provision opens a narrow door for hydrogen producers that cannot yet make a drop-in liquid.

The 90 % anti-tankering rule

Meanwhile tankering means loading more fuel than a flight needs, to avoid buying it at a more expensive destination airport. ReFuelEU Aviation requires aircraft operators to uplift at least 90 % of the yearly fuel they need at a given EU airport. Furthermore an operator may fall below that threshold where fuel safety rules require it, provided it justifies the gap and reports the quantities separately.

Exceptionally an operator can also request a temporary exemption for a specific route. The route must be shorter than 850 kilometres, or 1 200 kilometres where the airport sits on an island without rail or road connections. In practice the request must be filed at least three months before the exemption starts. It must also rest on serious and recurrent operational difficulties, or on limited supply. This rule matters less for a producer than the blending obligation. Still it shows how the regulation is built, because it targets behaviour at EU airports rather than the origin of the fuel.

Penalties, reporting and the 10-year transitional period

Also suppliers and operators both have reporting obligations, and non-compliance carries financial penalties that each Member State sets. However Article 12 fixes the floor. A supplier that misses the SAF share faces a fine of at least twice the difference between the average yearly price of conventional jet fuel and of SAF. That difference is multiplied by the quantity of fuel that did not comply.

For the synthetic sub-target the same logic applies, with the gap measured between synthetic aviation fuel and conventional fuel. Consequently the penalty is indexed to the very price gap that makes your project expensive. For that reason a fine is not a substitute for an offtake contract. In addition a supplier that ends a period with a shortfall must supply the missing quantity in the next period, on top of its new obligation. Nevertheless paying the fine does not erase that duty.

Moreover the final text of ReFuelEU Aviation introduces a 10-year transitional period. From 2025 to 2034, Article 15 lets a supplier meet the minimum share as a weighted average across all the aviation fuel it supplied at EU airports in that year. As a result the demand signal is real but not mechanical. Indeed a supplier keeps some room on where and when it blends.

How a batch is traced, claimed and reported

In practice the mandate rests on paperwork as much as on molecules. Under Article 9 an aircraft operator cannot claim the benefit of the same batch of SAF under more than one greenhouse gas scheme. Those schemes include the EU emissions trading system, CORSIA and national instruments. Therefore the same litre cannot be counted twice, once by a European airline and once inside a CORSIA claim.

For that reason aviation fuel suppliers must give aircraft operators accurate information on the SAF they delivered. Also the information is free of charge and due no later than 14 February of each reporting year. Moreover suppliers demonstrate compliance through a mass balance system, which two or more Member States may share. As a result three documents travel with every cargo your plant ships. They are the sustainability certificate, the batch number and the chain of custody record. Moreover a lender will read those three before it reads your financial model.

What ReFuelEU Aviation does not do

It does not set a SAF price.
It does not oblige an airline to sign a long-term contract with your plant.
Equally it does not pay for the price gap with fossil jet fuel.
It does not make a plant outside the EU eligible without certification.

As a result a mandate alone does not finance a plant. I cover the gap between rule and revenue in ReFuelEU Bankability: Can It Finance a SEA SAF Plant?.

What it means for a SAF developer in Southeast Asia

Similarly three consequences follow. First, EU demand is long-dated and regulated, which helps a lender’s demand case. Second, the obliged party is the fuel supplier, so your counterparty is often a supplier or trader before it is an airline (see ReFuelEU Offtake: Who Actually Buys Your SAF?). Third, distance and certification decide whether EU demand is reachable from your plant (see Export SAF to Europe).

If you are earlier in the process, start with How to Reach FID for a SAF Project and How to Finance a SAF Project. My work on sustainable aviation fuel and offtake agreements sits exactly at this junction.

What ReFuelEU Aviation changes for the revenue line

Therefore the mandate changes the shape of revenue rather than its level. A plant that sells into Europe sells into a market where the buyer has a legal reason to buy. However the buyer still has no legal duty to buy from you. In practice that produces three revenue patterns, and each one carries a different risk premium.

First, a merchant sale into the spot market captures the scarcity value of the mandate when supply is short. Still it gives a lender nothing to size a loan against. Second, a supply agreement with a fuel supplier or a trader converts the mandate into a volume commitment. That contract usually carries a price formula indexed to fossil jet plus a premium. Third, a tolling arrangement leaves the feedstock and the price risk with the counterparty. Instead your plant earns a processing fee.

Consequently the mandate helps most where the contract is longest. For a project in Southeast Asia the practical target is a buyer who must comply and who cannot source enough volume inside Europe. I develop that argument in ReFuelEU Offtake: Who Actually Buys Your SAF?.

What ReFuelEU Aviation changes for the contract

Moreover the regulation quietly rewrites the annexes of the offtake agreement. Certification stops being a closing condition and becomes a monthly obligation. The reason is that the compliance of your buyer depends on your paperwork arriving on time. In practice three clauses move to the front of the negotiation.

First, the specification clause must name the feedstock list and the certification scheme, not only the fuel grade. A change of feedstock can move a batch between eligible and ineligible. Second, the shortfall clause must say who carries the risk when a cargo is delayed. The shortfall of your buyer carries over into the following period, so timing becomes a contractual question. Third, the audit clause must give the buyer access to your mass balance records. That is what a national authority will inspect.

By contrast the price clause is the one part the regulation never touches. Therefore that leaves the premium open to negotiation. Consequently it also leaves you exposed to the gap between your cost of production and the price the buyer will pay. If you want to see how that gap is closed in practice, read How to Finance a SAF Project and Sustainable Aviation Fuel Price: What Sets It.

What a lender will ask to see

In addition a lender will treat ReFuelEU Aviation as a demand argument, not as security. For that reason the due diligence list on a Southeast Asia plant looks like this.

A certified pathway under the Renewable Energy Directive, with the greenhouse gas saving documented for each batch.
A named buyer that is a fuel supplier or a trader with an obligation at a specific EU airport.
A contract tenor that runs past the next step of the schedule, so the revenue case does not expire with a review of the regulation.
Evidence that the same batch will not be claimed twice, in Europe and under CORSIA.
Logistics that reach an EU airport without breaking the mass balance chain.

Consequently the question a credit committee asks is not whether the mandate exists. Instead it is whether your plant can deliver a certified batch to a named airport at a price the buyer has already agreed to pay.

Where the reach ends: Switzerland, the UK and the 2027 review

Overall ReFuelEU Aviation stops at the EU border, but not for long. Switzerland has applied ReFuelEU Aviation since 1 January 2026. Suppliers at Zurich and Geneva must therefore meet the same 2 % blend rising to 70 % by 2050, and airlines must respect the 90 % uplift rule there too. In addition the United Kingdom runs its own SAF mandate. Therefore a plant that sells to both markets carries two sets of certificates.

By contrast the global layer remains weak. At ICAO level the 41st Assembly adopted a long-term goal of net-zero emissions by 2050. In fact the EU regulation itself records that there is currently no mandatory scheme on the use of SAF for international flights. Therefore a developer should plan for Europe and Switzerland as regulated markets, and treat everything else as voluntary demand.

How the 2027 review could move the target

Furthermore ReFuelEU Aviation reviews itself on a fixed timetable. Under Article 17 the Commission must present a report by 1 January 2027, and every four years after that. Also the report must assess the possible revision of the scope, the SAF definition, the eligible fuels, the minimum shares and the level of fines. It must also consider support mechanisms to bridge the price gap with conventional fuel.

In addition the report must examine carbon leakage and rerouting. That matters to an Asian producer for an unexpected reason. For example if European carriers lose traffic to hubs outside the EU, the Commission has to weigh that loss against the ambition of the mandate. As a result a lender treats revision risk as a dated and visible event rather than an open-ended threat. A good credit file says what happens to the revenue case if the 2027 review softens a share or widens the flexibility mechanism.

Sources

Sources

Regulation (EU) 2023/2405 on ensuring a level playing field for sustainable air transport, Official Journal of the EU, 31 October 2023. eur-lex.europa.eu/eli/reg/2023/2405/oj/eng
European Parliamentary Research Service, “ReFuelEU Aviation initiative: Sustainable aviation fuels and the ‘fit for 55’ package”, PE 698.900, November 2023. europarl.europa.eu/thinktank
European Commission, DG MOVE, “ReFuelEU aviation”, including the Swiss application from 1 January 2026. transport.ec.europa.eu
European Commission, DG CLIMA, “Reducing emissions from aviation”. climate.ec.europa.eu

FAQ

Is ReFuelEU Aviation already in force?

Yes. In fact it has applied since 1 January 2024, and the core obligations on SAF shares have applied since 1 January 2025.

Who must blend SAF under ReFuelEU Aviation?

Aviation fuel suppliers must make the minimum share available at EU airports. Meanwhile airlines do not blend, but they must respect the 90 % uplift rule and report.

Does ReFuelEU Aviation apply to flights outside Europe?

In practice it applies to fuel supplied at airports in scope within the EU. Fuel made in Asia can count only if it meets the sustainability criteria and reaches an EU airport through the supply chain.

Which feedstocks are excluded?

In fact biofuels made from food and feed crops are excluded from the final scope. Eligible routes use residues, wastes, certain high-potential feedstocks and synthetic pathways.

Does the mandate guarantee a price?

No. Instead it creates a volume obligation, and the price comes from the contract.

Where does CORSIA fit?

By contrast CORSIA is a separate international scheme. I explain the difference in What Is CORSIA?.

Next step

A short call is usually enough to see where your project stands before a lender or an offtaker looks at it.

If your SAF project is pre-FID and you want to test how this regulated demand turns into contracts, book a 30-minute call or read about my project finance work.

I do not provide investment advice or arrange investments. I act as a strategic advisor and facilitator.